A note on version 2.6. This Policy is published ahead of the release of version 2.6 of the App so that you can read it before you update. Everything below describes the App as it is today, except the parts about advertising measurement, which are clearly marked and take effect only when you install version 2.6 or later. Version 2.5 sends nothing to Meta at all.
This Privacy Policy describes how Yusuf Demirtas, trading as Financebro Studio ("Financebro", "we", "us", "our"), collects, uses, and protects your information when you use the Financebro AI mobile application (the "App"). Financebro AI is a financial education and coaching service. It is not a brokerage, not a licensed financial advisor, and does not provide financial advice.
For the purposes of the EU/UK General Data Protection Regulation (GDPR), Türkiye's Law on the Protection of Personal Data No. 6698 (KVKK), and Brazil's General Data Protection Law No. 13.709/2018 (LGPD), the data controller (controlador, under the LGPD) is Yusuf Demirtas, an individual trading as Financebro Studio. Financebro Studio is a trading name, not a separate company; the person responsible for your data is named here so you always know who that is. You can reach us at financebrostudio@gmail.com.
Coaching responses in the App are generated by artificial intelligence (Anthropic's Claude). They may be incomplete, out of date, or incorrect, and must never be your sole basis for any financial decision. Always do your own research and consider consulting a licensed professional. The App shows no live prices and no market data — the coach has no access to either.
| Category | Examples |
|---|---|
| Account | Your Apple ID email (which may be an Apple private-relay address) when you sign in with Apple. We also create an anonymous identifier when you first open the App. |
| Profile you provide | First name, age, country, currency, occupation, the amount you can invest per month, experience level, risk tolerance, primary goal, time horizon, and your assigned investor archetype. |
| Your content | The messages you send to the coach. |
| Device & usage | A device push token (only if you enable notifications), product-analytics events, an analytics identifier, approximate location inferred from IP address, device model, and operating-system version. |
| Diagnostics | Crash reports and performance data. |
| Advertising measurement (version 2.6 and later) | While Advertising measurement is switched on in Settings: the fact that the App was installed, that it was opened, and that a subscription was purchased. These go to Meta so we can tell whether an advertisement worked. They carry your IP address and an identifier Meta's software creates for this App on your device, together with basic device and app information. They never carry your name, your profile, your goals, or your financial details. |
| Subscription | Your subscription status and plan. We do not receive or store your card or bank details — Apple processes all payments. |
We do not collect your income, financial-account balances, card numbers, contacts, photos, or precise GPS location.
For users in Brazil, the LGPD (Art. 7) provides equivalent legal bases for these activities, including performance of a contract, consent, legitimate interests, and compliance with a legal obligation.
We do not sell your personal information, and we do not track you across other companies' apps or websites — we never ask for the permission that would allow it, so we are never given the identifier that would make it possible. From version 2.6 we send a small set of events to Meta so we can measure whether our own advertisements worked; section 4 says exactly what those are, and you can switch them off in Settings → Advertising measurement.
| Provider | Purpose | Region |
|---|---|---|
| Supabase | Authentication & database | EU (Frankfurt) |
| Anthropic | AI processing of the questions you type and your recent conversation, together with profile details — your first name, age, country and currency, occupation, experience level, risk tolerance, primary goal, time horizon, the amount you can invest per month, your investor archetype, and your language preference. Under Anthropic's commercial API terms, the messages and profile details we send are not used to train Anthropic's or any other party's AI models. | US |
| RevenueCat | Subscription management | US |
| PostHog | Product analytics | US |
| Sentry | Crash & performance diagnostics | US |
| Apple | Sign-in, push notifications, payment | Global |
The recipient below does not act only on our instructions. It decides some of its own purposes for the data it receives, under its own terms, so we name it separately rather than calling it a service provider.
| Recipient | Purpose | Region |
|---|---|---|
| Meta Platforms, Inc. | Advertising measurement — app install, app open, and in-app purchase events, sent only while Advertising measurement is switched on in Settings. Meta may also use these events for its own purposes under its Business Tools Terms. No profile, goal, or financial details are ever included. | US |
If you are in Europe, none of this happens. In the European Economic Area, the United Kingdom and Switzerland the App does not start Meta's measurement software at all — no advertising event is sent, and no identifier is created for it. The law there requires consent before anything is placed on your device, and we do not ask for it, so we do not do the thing that would need it. That is also why you will not find an Advertising measurement switch in Settings on a device set to one of those regions: there is nothing for it to switch off. Everything below describes the App outside those regions.
If you found Financebro through an advertisement on Instagram or Facebook, we use Meta's measurement tools to understand whether that advertisement worked — whether it led to an install, and whether that install led to a subscription. We do not ask for permission to track you across other companies' apps and websites, and because we never ask, Apple never gives Meta the advertising identifier that would let it build a cross-app profile of you. We do not sell your information. Your financial details — the amount you told us you can invest, your goals, your risk tolerance — are never included in anything sent to Meta. If you would rather we did not measure this at all, switch Advertising measurement off in Profile → Settings; nothing further is sent from that moment.
Your account and content are stored in the EU (Frankfurt). Some recipients — analytics, crash reporting, AI processing, and advertising measurement — operate in the United States, so your data may be transferred there. Where required, such transfers rely on appropriate safeguards such as the European Commission's Standard Contractual Clauses; for transfers of data out of Brazil, we rely on the international-transfer bases permitted under the LGPD (Art. 33). By using the App you understand your data may be processed outside your country.
We keep your data while your account is active. When you delete your account, your data is removed promptly from our live systems; residual copies in encrypted backups are purged within 30 days on a rolling schedule. Aggregated, non-identifying analytics may be retained.
One limit worth stating plainly: events already sent to a third party before you deleted your account or switched a setting off — to Meta for advertising measurement, or to our analytics and crash-reporting providers — are held under that provider's own retention rules and we cannot recall them. Deleting your account stops anything further being sent.
Under GDPR, KVKK, Brazil's LGPD (Lei nº 13.709/2018), and the CCPA (as applicable), you have the right to access, correct, delete, port, restrict, or object to the processing of your personal data, and to withdraw consent. You can exercise the two most common rights directly in the App:
Step-by-step deletion instructions, including what is deleted and how to request it by email if you no longer have the App installed, are on our User Data Deletion page.
For any other request, email financebrostudio@gmail.com. You also have the right to lodge a complaint with your local data-protection authority (in Türkiye, the Kişisel Verileri Koruma Kurumu; in the EU, your national supervisory authority; in Brazil, the Autoridade Nacional de Proteção de Dados (ANPD)).
We use first-party analytics (PostHog) and crash reporting (Sentry) that rely on device and usage identifiers to measure how the App is used and to fix problems. Those two are used for our own product purposes only — never for advertising.
Separately, from version 2.6, Meta's measurement software sends install, app-open, and purchase events so we can tell whether our advertisements worked, while Advertising measurement is switched on in Settings. It creates its own identifier for this App on your device. It is not given Apple's advertising identifier (IDFA): we do not present an App Tracking Transparency prompt, and we switch off the identifier collection in Meta's software as well, so there are two independent reasons it never leaves your device. Without that identifier, Meta cannot join what it sees here to what you do in other companies' apps.
Note that Apple's App Store privacy label for this App nonetheless declares tracking. Apple counts embedding advertising software of this kind as tracking even when it is not used for that purpose, so the label is stricter than our actual behaviour rather than a description of it.
We use industry-standard measures including encryption in transit (HTTPS), encrypted storage of your authentication session in the device Keychain, and row-level access controls so each user can only access their own data.
The App is intended for users aged 16 and older and is not directed to children or to anyone under 16. We do not knowingly collect personal data from anyone under 16. If you believe someone under 16 has provided us data, contact us and we will delete it.
We may disclose information where we believe in good faith that it is necessary to comply with a valid legal obligation — a court order, subpoena, or lawful request from a public authority — or to establish, exercise or defend legal claims, or to protect the safety of a person. Apart from the recipients named in section 4, we will not disclose your information for any other reason. We do not sell your personal information. From version 2.6 we disclose app install, app-open, and purchase events to Meta for advertising measurement — section 4 explains exactly what that is, and section 14 explains how to switch it off.
Financebro Studio is currently operated by an individual. If it is incorporated as a company, reorganised, merged, or its assets are transferred to another business, your information may transfer with it so that the App can keep running and your account is not interrupted. Anyone receiving your information stays bound by this Policy until we tell you otherwise, and we will notify you in the App if the person or company responsible for your data changes.
We do not track you across other companies' apps or websites, so a "Do Not Track" signal has nothing to switch off, and our behaviour is the same whether or not one is sent. A "Do Not Track" signal is in any case a browser signal, and the App is not a browser — there is no way for it to receive one.
From version 2.6 the App contains one advertising-related component: Meta's measurement software, described in sections 4 and 8. It does not request Apple's advertising identifier. The switch that actually controls it is in the App itself — Profile → Settings → Advertising measurement.
Your rights under the CCPA/CPRA. If you live in California you have the right to know what personal information we have collected about you and how we have used and disclosed it, the right to delete it, the right to correct inaccurate information, and the right to opt out of any sale or sharing for cross-context behavioural advertising. We do not sell personal information. We do disclose a small set of advertising-measurement events to Meta, and rather than argue about whether that meets the statutory definition of “sharing”, we treat it as sharing and give you a switch — see Sale and sharing below.
How to make a request. Deletion and export are built into the App itself: Profile → Settings → Delete account or Export my data. To opt out of sharing for advertising measurement, use Profile → Settings → Advertising measurement — no request or email is needed, and it takes effect immediately. For anything else, or to make a request through an authorised agent, email financebrostudio@gmail.com. We will verify a request by matching it against the account details we already hold, and we will not use anything you send us for verification for any other purpose.
No discrimination. We will not deny you the App, charge you a different price, or give you a lower level of service because you exercised any of these rights.
"Shine the Light" (Cal. Civ. Code § 1798.83). We do not share personal information with third parties for those third parties' own direct-marketing purposes, and never have.
Sale and sharing. We have never sold personal information, for money or otherwise. Since version 2.6 the App discloses app install, app-open, and in-app purchase events to Meta so we can measure whether our own advertisements worked. Meta may use those events for its own purposes under its Business Tools Terms, which is why we treat this as sharing and offer an opt-out even though we do not build advertising profiles and Meta is not given the identifier that would let it recognise you elsewhere. Two things limit it: we apply Meta's Limited Data Use setting, which restricts how Meta may use data from users in California; and you can stop it entirely at Profile → Settings → Advertising measurement. Nothing is sent to Meta once that is off.
Categories of personal information (CCPA/CPRA). In the past twelve months we have collected the categories below.
| Category | Collected? | Source | Why | Disclosed to |
|---|---|---|---|---|
| Identifiers (Apple ID or private-relay email, account identifier, push token, IP address) | Yes | You; your device | Run your account, send notifications you asked for, measure whether our advertisements worked | Supabase, Apple, PostHog, Sentry, Meta |
| Personal information under Cal. Civ. Code § 1798.80 (first name) | Yes | You | Address you by name; let the coach address you by name | Supabase, Anthropic |
| Protected classifications (age) | Yes | You | Enforce the minimum age of 16; choose relevant examples | Supabase, Anthropic |
| Commercial information (subscription status and plan) | Yes | Apple / RevenueCat | Know what you are entitled to; measure whether an advertisement led to a subscription | RevenueCat, Supabase, Meta |
| Financial information (the amount you can invest per month) | Yes | You | Keep examples proportionate to your situation | Supabase, Anthropic |
| Internet or network activity (in-App feature events) | Yes | Your use of the App | Understand which features help | PostHog |
| Internet or network activity (app install and app open) | Yes, while Advertising measurement is on | Your use of the App | Measure whether an advertisement led to an install | Meta |
| Geolocation | Approximate only, inferred from IP address | Your device | Analytics and diagnosing crashes | PostHog, Sentry |
| Professional information (occupation) | Yes | You | Choose relevant examples | Supabase, Anthropic |
| Other information you give us (country, currency, experience level, risk tolerance, primary goal, time horizon, language) | Yes | You | Keep coaching and examples relevant to where you live and what you are trying to do | Supabase, Anthropic |
| Inferences (your investor archetype) | Yes | Derived from your answers | Give the coach a sense of how to pitch its answers, and show you on your Profile | Supabase, Anthropic |
| Biometric information | No | — | — | — |
| Precise geolocation | No | — | — | — |
| Government identifiers (Social Security number, passport, driver's licence) | No | — | — | — |
| Bank or card numbers, account balances | No — Apple processes all payments | — | — | — |
| Contacts, photos, audio recordings | No | — | — | — |
| Education records | No | — | — | — |
We may update this Policy from time to time. Material changes will be indicated by updating the "Last updated" date and, where appropriate, a notice in the App.
Yusuf Demirtas, trading as Financebro Studio — financebrostudio@gmail.com